No objections, support as written. Owen
> On Jun 23, 2020, at 10:38 AM, ARIN <[email protected]> wrote: > > The ARIN Advisory Council (AC) met on 18 June 2020 and decided to send the > following Recommended Draft Policy to Last Call: > > ARIN-2019-1: Clarify Section 4 IPv4 Request Requirements > > Feedback is encouraged during the Last Call period. All comments should be > provided to the Public Policy Mailing List. Last Call will expire on 8 July > 2020 (accounting for one United States federal holiday). > > The Recommended Draft Policy text is below and available at: > https://www.arin.net/participate/policy/drafts/ > > The ARIN Policy Development Process is available at: > https://www.arin.net/participate/policy/pdp/ > > Regards, > > Sean Hopkins > Policy Analyst > American Registry for Internet Numbers (ARIN) > > > > Recommended ARIN-2019-1: Clarify Section 4 IPv4 Request Requirements > > AC Assessment of Conformance with the Principles of Internet Number Resource > Policy: > > This Draft Policy is is fair, impartial, and technically sound. This draft > policy is an attempt to clarify the waiting period to only prohibit requests > for IPv4 allocations under Section 4 of the NRPM. Additionally, it disallows > organizations that have transferred space to other parties within the past 36 > months from applying for additional IPv4 space under NRPM Section 4. > > Problem Statement: > > Per a recent ARIN Policy Experience Report and resulting AC discussion, it > was noted that the language of Section 4.1.8 is imprecise in that it can be > interpreted as specifying a waiting period for any allocation activity, as > opposed to being intended to limit only the frequency of IPv4 allocations > under Section 4. > > The same Policy Experience Report also noted that ARIN staff has observed a > pattern where an organization transfers space under NRPM Section 8.2 to a > specified recipient, and then immediately applies for space under Section 4. > This activity appears to be speculative in nature and not consistent with > sound address management policy. > > The updated language in this proposal addresses the two issues above, as both > concerns can be addressed via modifications to the same section and sentence > thereof of the NRPM: > > - Clarifies the waiting period to only prohibit requests for IPv4 allocations > under Section 4 of the NRPM > > - Disallows organizations that have transferred space to other parties within > the past 36 months from applying for additional IPv4 space under NRPM Section > 4. > > Policy Statement: > > Current language found in NRPM Section 4.1.8 - Unmet Requests: > > Repeated requests, in a manner that would circumvent 4.1.6, are not allowed: > an organization currently on the waitlist must wait 90 days after receiving a > distribution from the waitlist before applying for additional space. ARIN, at > its sole discretion, may waive this requirement if the requester can document > a change in circumstances since their last request that could not have been > reasonably foreseen at the time of the original request, and which now > justifies additional space. Qualified requesters will also be advised of the > availability of the transfer mechanism in section 8.3 as an alternative > mechanism to obtain IPv4 addresses. > > Proposed new language 4.1.8: > > Multiple requests are not allowed: an organization currently on the waitlist > must wait 90 days after receiving a distribution from the waitlist or IPv4 > number resources as a recipient of any transfer before applying for > additional space. ARIN, at its sole discretion, may waive this requirement if > the requester can document a change in circumstances since their last request > that could not have been reasonably foreseen at the time of the original > request, and which now justifies additional space. Qualified requesters will > also be advised of the availability of the transfer mechanism in section 8.3 > as an alternative mechanism to obtain IPv4 addresses. > > Restrictions apply for entities who have conducted recent resource transfers. > These restrictions are specified in Section 8 for each relevant transfer > category. > > Add the following under 8.2. Mergers, Acquisitions, and Reorganizations: > > An organization which serves as the source of an 8.2 IPv4 transfer will not > be allowed to apply for IPv4 address space under section 4.1.8 ARIN Waitlist > for a period of 36 months following said transfer unless the recipient > organization remains a subsidiary, parent company, or under common ownership > with the source organization. > > Add the following under 8.3. Transfers Between Specified Recipients Within > the ARIN Region and under the Conditions on the source of the transfer: > > The source entity will not be allowed to apply for IPv4 address space under > Section 4.1.8. ARIN Waitlist for a period of 36 months following the transfer > of IPv4 address resources to another party. > > Under conditions on the recipient: > > If applicable the recipient will be removed from the ARIN Waitlist and will > not be allowed to reapply under section 4.1.8. ARIN Waitlist for a period of > 90 days. > > Add the following under 8.4. Transfers Between Specified Recipients Within > the ARIN Region and under the Conditions on the source of the transfer: > > The source entity will not be allowed to apply for IPv4 address space under > Section 4.1.8. ARIN Waitlist for a period of 36 months following the transfer > of IPv4 address resources to another party. > > Under conditions on the recipient: > > If applicable the recipient will be removed from the ARIN Waitlist and will > not be allowed to reapply under section 4.1.8. ARIN Waitlist for a period of > 90 days. > > Add: > > 8.6 Wait List Restrictions > > Any organization which is on the wait list and submits a request to be the > source of a transfer under any provision in section 8 will be removed from > the wait list. > > Timetable for Implementation: Immediate > > Comments: > > This proposal incorporates two related policy goals, combined for convenience > in one proposal as both can addressed via modification of the same section > and sentence of the NRPM. During ARIN 43 it was proposed to the community > that the two policy statements were severable, however, there was sufficient > community support behind keeping both. > > There have been updates to section 4 since the beginning of the work on this > policy. Text has been updated to reflect current NRPM. > > There was significant community support to change the word “repeated” as it > was vague. Additionally, there was concerned that a company may perform an > M&A transfer to itself/parent company and the original proposed language > would exclude those companies from being able to apply to the waitlist. After > the addition of the new merger and acquisition language, staff and legal > recommended that the restrictions for applying to the waitlist for > participants of the transfer market be added to the appropriate section in > the Section 8 of the NRPM. Organizations should be informed of how their > activities in the transfer market will impact them in reference to applying > to the waitlist. These changes were to make it easier for staff and the > community to understand these requirements. > > _______________________________________________ > ARIN-PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List ([email protected]). > Unsubscribe or manage your mailing list subscription at: > https://lists.arin.net/mailman/listinfo/arin-ppml > Please contact [email protected] if you experience any issues. _______________________________________________ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List ([email protected]). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact [email protected] if you experience any issues.
